Justia U.S. 8th Circuit Court of Appeals Opinion Summaries

The EEOC filed suit alleging that North Memorial violated 42 U.S.C. 2000e-3(a), by unlawfully retaliating against an employee. The district court granted summary judgment for North Memorial and dismissed the claim, concluding that North Memorial did not violate section 2000e-3(a) because it did not discriminate against the employee.The Eighth Circuit affirmed and held that the EEOC failed to establish a prima facie case of opposition-clause unlawful retaliation because merely requesting a religious accommodation was not the same as opposing the allegedly unlawful denial of a religious accommodation. The court reasoned that, when an employee or applicant requested a religious accommodation, and the request was denied by an employer such as North Memorial that accommodated reasonable requests that did not cause undue hardship, there was no basis for an opposition-clause retaliation claim under Sec. 2000e-3(a). The court held that the employee or applicant's exclusive Title VII remedy was an unlawful disparate treatment or disparate impact claim under section 2000e-2(a)(1). View "EEOC v. North Memorial Health Care" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for Saint Luke's in an employment discrimination action. The court held that the district court did not abuse its discretion in denying defendant's motion to reconsider under Federal Rule of Civil Procedure 60(b)(1). The court explained that, although defendant's delay was brief, Saint Luke's made no claim of prejudice and defendant did not act in bad faith, such factors did not outweigh defendant's carelessness or mistake in construing the rules and the absence of any apparent meritorious defense. Furthermore, there were no exceptional circumstances in this case that warranted relief under Rule 60(b)(6). View "Giles v. St Luke's Northland-Smithville" on Justia Law

The Eighth Circuit affirmed the district court's dismissal of a petition for habeas corpus under 28 U.S.C. 2254 where petitioner was convicted of two counts of first-degree rape and two counts of sexual contact with a child under the age of 16. The court held that petitioner failed to exhaust his remedies in regard to his claim that admission of a video of the victim implicated his rights under the Confrontation Clause; petitioner also failed to raise the Confrontation Clause issue before the district court; and the evidence at trial, including the video, provided an adequate basis for conviction. View "Brende v. Young" on Justia Law

Plaintiffs filed suit against defendants after plaintiff's son, Michael, was killed by cardiac arrhythmia after an altercation with officers in the setting of acute methamphetamine intoxication. When officers responded to a domestic disturbance call, they found Michael brutally attacking his girlfriend.The Eighth Circuit affirmed the district court's grant of summary judgment for defendants, holding that unsworn statements from paramedics to law enforcement were properly excluded and the district properly disregarded them; Iowa's false statement statute did not implicitly swear a declarant making a statement to law enforcement; there was no genuine dispute of material fact that Michael posed a threat to the safety of the officers and the victim and no competent, admissible evidence rebutted the officers' version of the events; because there was no constitutional violation, the court need not consider whether the rights at issue were clearly established. The court also affirmed the district court's decision not to exercise jurisdiction over the state law claims. View "Zubrod v. Hoch" on Justia Law

The Eighth Circuit affirmed the district court's grant of summary judgment for DCDC in an action alleging claims of gender, age, and disability discrimination under state and federal civil rights laws. Plaintiff, a 56 year old woman, worked as a correctional officer until she was injured in inmate altercations. After plaintiff worked the maximum allowable number of days of light duty pursuant to the terms of the Collective Bargaining Agreement (CBA), she was terminated when no other suitable position was found.The court held that plaintiff failed to establish a prima facie case of sex discrimination; plaintiff's prima facie evidence of bad faith supporting her claim of failure to accommodate/disability was rebutted by the incontrovertible evidence that plaintiff could not have been reasonably accommodated; and plaintiff's age discrimination claim failed because she did not produce evidence of a similarly situated younger person who was treated differently. View "Faulkner v. Douglas County" on Justia Law

The Eighth Circuit reversed the district court's denial of summary judgment for a sheriff's deputy in an action filed by plaintiff under 42 U.S.C. 1983, alleging that the deputy used excessive force while arresting her. The court held that the deputy was entitled to qualified immunity where it was not clearly established at the time that a deputy was forbidden to use a takedown maneuver to arrest a suspect who ignored the deputy's instruction to "get back here" and continued to walk away from the officer. View "Kelsay v. Ernst" on Justia Law

The North Dakota Secretary of State filed a motion to stay an order of the district court that enjoined parts of the North Dakota elections statutes. The district court enjoined the Secretary from enforcing a provision that required a voter to present at the polls a valid form of identification that provides the voter's current residential street address.The Eighth Circuit granted the motion and held that the Secretary demonstrated a likelihood of success on the merits in his challenge to this aspect of the injunction, the State would be irreparably harmed by the injunction during the general election in November, and a stay should be granted after consideration of all relevant factors. View "Brakebill v. Jaeger" on Justia Law

The Eighth Circuit affirmed the district court's judgment granting petitioner's application for habeas corpus relief from his death sentence pursuant to 28 U.S.C. 2254. The court held that, because the district court's partial grant of petitioner's rule 59(e) motion was not subject to this appeal, the court did not address the merits of the district court's application of Martinez v. Ryan, 132 S.Ct. 1309 (2012), and its finding of extraordinary circumstances.The court also held that the district court's finding that petitioner was prejudiced by counsel's deficient performance was supported by the evidence. Therefore, the district court properly concluded that petitioner established ineffective assistance of counsel. The court agreed with the district court that, as to Ground I, petitioner's Rule 60(b) motion was not a successive claim under 28 U.S.C. 2244(b). Finally, the district court did not err in denying respondent's Rule 59(e) motion; the judgment granting habeas relief was not the result of any manifest error; and the motion was not supported by any showing of extraordinary circumstances. View "Barnett v. Roper" on Justia Law

Plaintiffs filed suit under 42 U.S.C. 1983, challenging procedures used in proceedings brought by the State to remove Native American children temporarily from their homes in exigent circumstances. The district court denied defendants' motion to dismiss on jurisdictional grounds and granted partial summary judgment for plaintiffs. The district court then entered a declaratory judgment and permanent injunction.The Eighth Circuit held that the district court should have abstained from exercising jurisdiction under principles of federal-state comity articulated in Younger v. Harris, 401 U.S. 37 (1971), and later cases. In this case, even setting aside the question of “ongoing” temporary custody proceedings, plaintiffs may not circumvent the abstention doctrine by attempting to accomplish the same type of interference with state proceedings through a claim for prospective relief. Therefore, the court vacated the district court's order and remanded with instructions to dismiss the claims that gave rise to the orders. View "Oglala Sioux Tribe v. Vargo" on Justia Law

After plaintiff was appointed as a presidential elector during the 2016 presidential election, he was deemed to have vacated his position under Minnesota's Uniform Faithful Presidential Electors Act, Minn. Stat. 208.40-208.48, when he attempted to vote for candidates other than those to whom he was pledged. Plaintiff then filed suit challenging the constitutionality of the Minnesota statute and to enjoin Minnesota officials from counting the vote of the substitute elector.The Eighth Circuit affirmed the district court's dismissal of the action as moot where Congress had counted the Minnesota elector votes, and denied plaintiff's motion to supplement the record and to remand for further proceedings on mootness. The court held that plaintiff failed to establish that his action fell within the mootness exception for cases that were capable of repetition yet evading review because plaintiff failed to file his action sooner. View "Abdurrahman v. Dayton" on Justia Law